UNITED STATES AND CANADA PRIVACY POLICY

SITE OPERATION

This website and its related downloadable applications and services (collectively, our “Website”) is operated, hosted, and
maintained by 365 Connect, LLC (“365 Connect,” “we,” “our,” or “us”) and is
licensed for use by us to the legal entity (“Subscriber”) that owns or
manages the property featured on this Website (collectively the “Property
Management Company”). In addition to information, materials, products, and
services from the Property Management Company, this Website may also
feature information, materials, products, and services provided by third
parties, including but not limited to, content providers, payment
processors, advertisers, and other service providers (collectively, the
“Third Party Providers”). This privacy policy (“Privacy Policy”) applies
solely to this Website. The terms "you," "your," and "user" (collectively
the “Users”) refer separately to each person (each individual and each
entity for whom the individual acts) that accesses or uses this Website.

Through this Website we assist the Property Management Company in managing
their property and other assets by, among other things, facilitating
communication and transactions between Users, Third Party Providers, and
the Property Management Company. We merely host or process data and
personal information about Users (“Personal Information”) on behalf of the
Property Management Company and Third Party Providers, and have no direct
relationship with Users. We are a data processor and not a data controller
with respect to your personal information.

Our top priority is protecting the privacy and security of any Personal
Information about you collected or used on our Website, as well as
maintaining the trust of our Subscriber. This includes both data submitted
by the Subscriber and Personal Information submitted by Users to our
Website.

This Privacy Policy applies solely to information collected by us about
users who are residents of the United States or Canada and access or use
this Website. If you are a resident of the European Union, view our EU Privacy Policy.

We collect and pass on information in connection with the operation and
purposes of our Website, and also collect and pass on information to the
Property Management Company and Third Party Providers to use and share for
its own purposes. This Privacy Policy addresses our collection, use, and
sharing of information about you, and not the collection, use, or sharing
of information about you by the Property Management Company or other Third
Party Providers, as to which you should consult their respective privacy
policies.

We encourage you to read this Privacy Policy and our Website Terms of Use before you send or share Personal Information with us
or use this Website, and to read them again at each return visit.

A USER WHO NAVIGATES THIS WEBSITE GIVES PERMISSION TO US TO SHARE ANY
OR ALL PERSONAL INFORMATION THAT YOU PROVIDE TO THE PROPERTY MANAGEMENT
COMPANY AND THIRD PARTY PROVIDERS WHILE USING THIS WEBSITE IN
FURTHERANCE OF SEEKING TO RENT OR LEASE RESIDENTIAL HOUSING, OR ACCESS
AND USE SERVICES THAT ARE AVAILABLE ON THIS WEBSITE.IF YOUR DO NOT CONSENTOR
AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THIS WEBSITE.
CONTINUED USE OF THIS WEBSITE CONSTITUTES YOU HAVE FREELY GIVEN SPECIFIC AND INFORMED CONSENT ANDAGREEMENT TO YOUR PERSONAL INFORMATION BEING PROCESSED PURSUANT TO THIS
PRIVACY POLICY.

WEBSITES COVERED UNDER THIS PRIVACY POLICY

This Privacy Policy describes our privacy practices regarding what specific
information we collect from you when you visit this Website, and also any
associated or related Websites (collectively the “Websites”) that contain a
link to this Privacy Statement only.

THIS PRIVACY POLICY DOES NOT APPLY TO OTHER WEBSITES

Our confidentiality, privacy, and other obligations related to the services
we provide to the Property Management Company for the property that is
featured on this Website, is limited to this Website only, and does not
extend beyond this Website. The Property Management Company may own,
operate, license or list the same property on other websites, online
marketplaces, and advertisements, which may contain their own Privacy
Policy and Terms of Use, which we strongly encourage you read before using
those respective websites. The Property Management Company may also use
separately owned or third-party websites for the processing of rental
applications, agreements, payments, and other services to assist you in
either qualifying for rental housing or providing services to you. Those
owned or third-party websites may contact a link on this Website for the
purpose of convenience. Upon clicking a link, you may leave this Website to
engage with those websites, for which they will contain their own Privacy
Policy and Terms of Use, which we strongly encourage you to read before
using those respective websites. Please be advised that this Privacy
Statement is not applicable to those websites, which are instead governed
by their own respective privacy statements.

PLEASE BE ADVISED THAT THIS PRIVACY POLICY IS NOT APPLICABLE TO ANY OF
YOUR PERSONAL INFORMATION THAT IS SHARED BY US WITH THE PROPERTY
MANAGEMENT COMPANY, THEIR PARTNERS, THIRD PARTY PROVIDERS, AND ANY
OTHER THIRD PARTIES TO ASSIST USERS WHO PARTICIPATE IN THE APARTMENT
RENTAL SEARCH, APPLICATION PROCESS, OR WHO MIGHT BECOME RESIDENTS OF
THE PROPERTY FEATURED ON THIS WEBSITE. ALL PERSONAL INFORMATION THAT IS
SHARED BY US WITH THE PROPERTY MANAGEMENT COMPANY, THEIR PARTNERS AND
THIRD PARTIES IS GOVERNED BY THE PRIVACY STATEMENTS OF THE PROPERTY
MANAGEMENT COMPANY, AND THEIR PARTNERS, OR THIRD PARTIES WHO CREATE AND
MANAGE THEIR OWN WEBSITES AND PROVIDE SERVICES TO YOU, AND HAVE NOTHING
TO DO WITH US, AND ARE NOT UNDER OUR CONTROL.

The Property Management Company and Third Party Providers make their own
decisions about how or why Personal Information is to be processed,
including any disclosure or transmission to third parties. If Personal
Information relating to you as an individual has been submitted or entered
into this Website, or was otherwise collected by us on behalf of the
Property Management Company or Third Party Providers, and you wish to
exercise any rights you may have to access, correct, amend or delete such
Personal Information, please contact the Property Management Company or
Third Party Providers directly. If an authorized Property Management
Company or Third Party Providers representative requests that we update or
remove the Personal Information in question, and the Property Management
Company or Third Party Providers has no ability to do so, we will
acknowledge their request within 30 days.

Any use of Personal Information by us is done so pursuant to the agreements
between us, the Property Management Company and any Third Party Providers,
and in accordance with the Terms of Service published on this
Website. This Privacy Policy does not apply to any Personal Information the
Property Management Company or any Third Party Providers may collect or
process from you. If you have any questions or concerns about the data
practices of the Property Management Company or any Third Party Providers
that are using our services to process your Personal Information, you need
to contact them directly, and ask for their Privacy Policy or Privacy
Statement.

PERSONAL INFORMATION WE COLLECT

We collect Personal Information from this Website in order to provide
information, facilitate communication, transactions, and services between
you and the Property Management Company, Third Party Providers, and to help
us better understand how we can assists Users that are searching for
residential apartments to rent, lease, or obtain services as a resident in
the apartment they occupy.

The different types of Personal Information we collect will depend upon
what we will need in order to provide you with the particular product or
service you are interested in. The information requested on our
registration form includes some or all of the following Personal
Information: name, address, email address, telephone number, user name,
password, and birth month, day and year, and will include other information
that you provide voluntarily (i) in connection with your use of any
interactive tools or resources on this Website relating to finding,
leasing, or accessing services for an apartment, including submission of an
inquiry, contact or schedule a visit form, lease application or related
payment, such as your name, social security number, social insurance
number, driver's license number, present and prior postal addresses, zip
codes, postal codes, telephone numbers and email addresses, monthly rent
paid at previous residences, gender, age, marital status, date of birth,
employers, job titles, occupation, income, references, and payment-related
information, such as credit card information, bank account information and
routing numbers, emergency contact information, and information about your
pets and vehicles, including license plate numbers, (ii) in connection with
your submission of rental payments, service requests, or other
communications with the Property Management Company, its agents or Third
Party Providers, such as your name, address, telephone number, email
address, automated clearing house (ACH) information, debit or credit card
information, and/or the nature of work requested, (iii) in connection with
your use of any interactive educational or informational resources provided
to residents, (iv) in any postings you make in any Community or otherwise
on our Website or in any emails that you send to us, (v) in connection with
your use or purchase of any other services or products provided by this
Website or by any Third Party Providers, such as your debit or credit card
information and your purchase history, or (vi) in connection with your use
of any other aspect of this Website. Certain services and features on this
Website may only be used if you voluntarily provide certain information
about you.

Those interested in touring, inquiring, renting or leasing a residential
apartment will likely be asked to include the following additional
information: the type of apartment or apartment size you are looking for,
where you want to live, the type of building you prefer, your proposed rent
budget, the number of individuals in your household and their ages, and if
you have pets or not.

THIS INFORMATION WILL BE SHARED WITH THE PROPERTY MANAGEMENT COMPANY OR
THIRD PARTY PROVIDERS THAT OWN, MANAGE, SERVE, OR OPERATE THE
RESIDENTIAL APARTMENTS YOU ARE SEEKING TO RENT, LEASE, OR OBTAIN
SERVICES AS A RESIDENT IN THE APARTMENT YOU OCCUPY.

USAGE TRACKING: USE OF IP ADDRESSES

Every device that connects to the Internet is given a number that is known
as an Internet Protocol (IP) Address. These numbers are typically assigned
in geographic blocks. An IP address can often be used to identify the
location from which a device is connecting to the Internet. As permitted
under applicable law, we collect IP addresses for the purposes of system
administration, gathering and analyzing aggregated information, creating a
better experience for Users and auditing the use of our site.

We do not usually link any IP addresses to anything that can be personally
identifiable. This means that your Internet session will be logged, but you
will remain anonymous to us. We will seek to link your IP address to
personally identifiable information when we deem it necessary (i) to
identify and authenticate you when you submit certain information to the
Website, such as request to visit the property, payments, request for
services or other types of communication, (ii) to be pre-qualified for
rental housing displayed on this Website, (iii) when you start or complete
a lease application for rental housing displayed on this Website, or (iv)
to protect this Website and other Users from harm and to prevent criminal
misconduct.

USE OF COOKIES

A cookie is a small file which contains a string of characters that is sent
to your computer when you are browsing the Internet and visit a website.
When you visit the same website again, the cookie enables that site to
recognize your browser. Cookies may store User preferences and other
information about you. You can configure your browser to refuse all
cookies, or to indicate when a cookie is being sent. However, there are
some website features or services that may not function properly without
cookies.

Improvements and updates to this Website are based on such data as total
number of visitors and pages viewed. This information is most easily
tracked with cookies. We use the information from cookies only to provide
services better suited to your needs, and for the protection of our Website
and Users from potential harm. We never save passwords or credit card
information in cookies.

We may use cookies for many purposes, including to remember your safe
search preferences, to track Users’ movements around this Website, to
analyze trends, administer this Website, to count how many visitors we
receive to a page, to help you sign up for our services, to protect your
data and to gather demographic information about our User base as a whole.
Users can control the use of cookies at the individual browser level. We
may partner with a third party to either display advertising on our website
or to manage advertising on other sites. A third party partner may use
cookies or similar technologies in order to provide advertising or other
content to you, based upon your browsing activities and interests or to
make the ads you see more relevant to you.

If you desire to change your cookie preferences, you can do so through your
browser settings. You may also limit the information we learn from certain
cookies by logging directly into the registered areas of this Website
rather than by logging in by using your social media log-in credentials. Be
advised that our cookies are often used to provide you with certain
functionality, and without them you may not be able to use some of the
services provided on this Website.

WEBSITE ANALYTICS

This Website may use web analytics tools and services, some from third
parties, such as web analytic services provided by Google, Inc. (“Google”),
to better assist us in understanding how this Website is used. These web
analytics tools and services will place cookies on your computer that will
generate information that we select about your use of this Website,
including your computer’s Internet Protocol (IP) Address. That information
will be transmitted to and stored by us and or third parties. The
information will be used for the purpose of evaluating consumer use of this
Website, compiling reports on Website activity for our use, and providing
other services relating to Website activity and usage. We may also transfer
this information to third parties where required to do so by law, or where
such third parties process the information on our behalf. You may refuse
the use of cookies by selecting the appropriate settings on your browser.
Please note that by doing so, you may not be able to use the full
functionality of this Website. Use of cookies by Google Analytics is
covered by Google’s privacy policy located at
https://policies.google.com/privacy.

OUR USE OF INFORMATION ABOUT YOU

We may use Personal Information about you to create your account, to enable
you to use this Website, including any communities, and to facilitate
communication and transactions between Users and the Property Management
Company, and other Third Party Providers for transactions between you and
any of them through this Website, including but not limited to using
information about you (i) in connection with any interactive
decision-making tools or resources relating to leasing an apartment,
including submission of an inquiry, contact or schedule a visit forms,
lease application or related payments, (ii) in connection with assisting
the Property Management Company and Third Party Providers in marketing to
you, including contacting you by email, phone, text message, or otherwise,
(iii) in connection with assisting the Property Management Company and
Third Party Providers in processing your lease application, including
investigating your background, leasing history, and creditworthiness
through third parties, including consumer reporting agencies, (iv) in
connection with processing your rental payments, service requests, and
other communications with the Property Management Company and Third Party
Providers, (v) in connection with your use of any interactive educational
or informational resources provided to residents, (vi) in connection with
your participation in any community or in dealing with any emails that you
send to us, (vii) in connection with your use or purchase of any other
services or products provided by this Website or by any third-party
provider, (viii) in connection with your use of any other aspect of this
Website, and (ix) generally to enhance and optimize your use of this
Website. We may also use your email address or telephone number to respond
when you submit a question, suggestion, or request assistance with using or
accessing this Website.

We may link Personal Information we collect about you with other Personal
Information we collect about you, whether offline or from third parties or
otherwise. We may use Personal Information about you to send you targeted
messages, publications, news, and information about events, special offers,
promotions, benefits, and other advertisements. We may use Personal
Information about you to improve, to analyze trends, to administer this
Website, to gather demographic information about this Website's users, to
track user movements, and to customize the content and layout of this
Website for each individual user.

INFORMATION WE SHARE OR DISCLOSE

We may share Personal Information about you with the Property Management
Company, Third-Party Providers and others (such as hosting service
providers, analytics service providers, email service providers, lease
screening service providers, custom programmers, payment processors,
advertisers, etc.) and other appropriate persons for purposes of (i)
performing functions pertinent to this Website's apparent and reasonable
purposes, including but not limited to those discussed above under "Our Use
of Information About You"; (ii) maintaining, upgrading, and improving this
Website; (iii) complying with law, cooperating with governmental
authorities, and consulting with our attorneys and other advisers; (iv)
attempting to avert a threat of harm to our, or others' safety, or other
interests; (v) defending us and our members, managers, officers, employees,
and affiliates in connection with any legal actions or claims; and (vi)
enforcing the Terms of Use of this Website. We also reserve the
right to transfer personal information about you to a third party that
acquires substantially all of our assets.

Similarly, the Property Management Company, Third-Party Providers and
others (such as lease screening service providers, payment processors,
advertisers, etc.) may share Personal Information about your use of this
Website with other appropriate persons for purposes of (i) performing
functions that would reasonably be expected of a Property Management
Company with respect to a prospective renter, such as contacting you by
email, phone, text message, or otherwise to market its space and
investigating your background, leasing history, creditworthiness, either
directly or through the assistance of third parties, including credit
reporting agencies, (ii) complying with law, cooperating with governmental
authorities, and consulting with attorneys and other advisers, (iii)
attempting to avert a threat of harm to its, or others' safety, or other
interests, (iv) defending it and its owners, personnel, and affiliates in
connection with any legal actions or claims, and (v) other purposes of the
Property Management Company in or outside the ordinary course of its
business.

We may use Third-Party Providers to send and distribute email and to
perform other marketing and support functions. We may share Personal
Information about you with third parties who offer goods and services we
think may be of interest to you. From time to time, we may cooperate with
other organizations or companies to provide co-sponsored or co-branded
promotions, services or events and may share Personal Information about you
with our co-sponsor. We also may provide Personal Information about you to
service providers or contractors to perform functions on our behalf, such
as, but not limited to, companies or individuals hired to: communicate
news, deliver our promotional materials via e-mail and direct mail, to
develop, enhance, market or provide any of our products, to process credit
card payments and to assist us with sending communications and performing
other marketing and support functions. These third parties may use
technologies to measure the effectiveness of ads and emails, and use
Personal Information about your visits to this Website so that we may
provide you with a better experience on this Website. We also may use
third-party social media platforms, including third-party social media
websites, to communicate with you. We also may share with third parties
aggregated demographic and statistical information, such as the daily
number of unique visitors to this Website, the number of users who searched
for certain types of housing, and how many users clicked on a particular
advertisement.

We also may disclose Personal Information about you (i) to a person who in
our good faith judgment appears to be you or your agent, (ii) to a third
party or parties where disclosure is required or permitted by law, a
judicial proceeding, a criminal investigation, a court order, or legal
process, (iii) if, in our good faith judgment, it is necessary or desirable
to enforce compliance with our internal policies or the Terms of Use
, to try to prevent illegal activity or suspected fraud, or to try to
protect this Website, customers, or others; and (iv) to any other entity
that acquires all or a portion of our organization by merger,
reorganization, operation of law, or a sale of some or all of our assets.

Through this Website, we may make available areas that allow for User
interaction with other users, such as blogs, forums, bulletin board
services, chat areas, or other message and communications features. Some of
these forums may require registration. Please remember that any Personal
Information that is disclosed in these areas becomes public information,
and you should exercise caution when deciding to disclose Personal
Information about yourself.

We do not rent or sell your Personal Information in a personally
identifiable form to anyone, provided however, certain Personal Information
may be shared with the Property Management Company, Third-Party Providers
and others such as hosting service providers, analytic service providers,
email service providers, lease screening service providers, custom
programmers, payment processors, advertisers as more fully described above.

We may anonymize your Personal Information so that you are not individually
identified, and provide that information to our partners and also third
parties. We may also provide aggregate usage information to our partners,
who may use such information to understand how often and in what ways
people use our Website, so that they, too, can provide you with an optimal
online experience.

Advertisers: We may allow advertisers and/or merchant partners
(“Advertisers”) to choose the demographic information of Users who will see
their advertisements or promotional offers, and you agree that we may
provide any of the Personal Information we have collected from you in a
form that is not personally identifiable to Advertisers, in order for that
Advertiser to select the appropriate audience for those advertisements
and/or offers. For example, we might use the fact you are located in
Houston to show you ads or offers for Houston businesses, but we will not
tell such businesses who you are. Or, we might allow Advertisers to display
their ads to Users with similar usage patterns to yours, but we will not
disclose usage information to Advertisers except in aggregate form, and not
in a manner that would identify you personally. Note that if an advertiser
asks us to show an ad to a certain audience or audience segment, and you
respond to that ad, the advertiser may conclude that you fit the
description of the audience they were trying to reach.

Affiliated Businesses: In certain situations, businesses or third party
websites we might be affiliated with may sell or provide products or
services to you through, or in connection with this Website (either alone
or jointly with us). You can recognize when an affiliated business is
associated with such a transaction or service, and we will share your
Personal Information with that affiliated business only to the extent that
it is related to such transaction or service. We have no control over the
policies and practices of third party websites or businesses as to privacy
or anything else, so if you choose to take part in any transaction or
service relating to an affiliated website or business, please review all
such businesses’ or websites’ policies.

Agents: We might employ other companies and people to perform tasks on our
behalf and need to share your Personal Information with them to provide
products or services to you. Unless we tell you differently, our agents do
not have any right to use the Personal Information we share with them
beyond what is necessary to assist us.

REVIEWS AND CONTENT SUBMISSIONS

This Website may allow you to provide and submit certain content
(“Content”) in the form of a review or rating as to your experience in
visiting or living at the properties featured on this Website. We may share
your content with the Property Management Company, Third-Party Providers
and others (such as review publishers, search engines, analytic service
providers, syndication sites, advertisers, etc.), and other appropriate
persons for purposes of publication to this Website, social media channels,
as well as other third party websites.

THIRD PARTY PROVIDERS

It is our intention to maintain reputable Third-Party Providers to offer
Users a variety of products and services on this Website. We are not
responsible for their information, privacy, or other business practices.
When choosing to purchase products or services on this Website, you must
take into consideration that you will be transacting business directly with
a Third-Party Provider, and the Personal Information about you, collected
by the provider, will be subject to the practices of that provider.

THIRD PARTY WEBSITE LINKS

This Website may contain links to third party websites that are beyond our
control, and take you outside of this Website. For example, if you "click"
on a banner ad, which is an advertisement or a search result, the "click"
may take you off this Website and on to another site that is beyond our
control. These other websites may include sites of other sponsors,
advertisers or partners that may use their logo with ours as part of a
co-branding agreement. These other websites might also send their own
cookies to Users who become visitors to their websites to collect data or
solicit information. We do not control these websites and therefore are not
responsible for their content. The inclusion of hyperlinks to any other
websites by us on this Website, does not infer any endorsement of the
content or material on such websites, nor any association with the owners
or operators of the websites or the businesses listed on any of these
websites. Our policies do not extend to anything that is inherent in the
operation of the Internet, which is beyond our control. Be advised that if
you disclose Personal Information online, that all such Personal
Information may be collected and used by people you do not know.

The information practices or content of such other websites or advertisers
is governed by the privacy statements of all such other websites and
businesses contained on those websites. Please be advised that this Privacy
Statement is not applicable to those websites and businesses, which are
instead governed by their respective privacy statements. Please review the
privacy statements of such other websites and businesses to understand
their Personal Information collection practices.

TRACKING

When this Website receives web browser "do not track" signals (or other
mechanisms that provide consumers the ability to exercise their choices
regarding the collection of personally identifiable information about a
consumer's online activities over time and across third-party websites or
online services), our Website does not alter its behavior. Other parties
may collect personally identifiable information about an individual
consumer's online activities over time and across different websites when
the consumer uses this Website or its services.

SAFEGUARDING YOUR INFORMATION

We take all reasonable and appropriate measures to protect your Personal
Information from loss, misuse and unauthorized access, disclosure,
alteration and destruction; taking into account the risks involved in the
processing and the nature of the Personal Information.

Our resident services and application accounts require a username and
password to log in. You must keep your username and password secure, never
disclose it to a third party, and do not allow others to utilize your
account. You should fully exit from your account at the end each session,
by utilizing the logout feature. You should also implement a practice of
changing your password on a regular basis. If Users have any questions
about security, please contact us at: notices@365connect.com

CHILDREN UNDER 13 YEARS OF AGE

Our Website is not intended for children under 13 years of age. We do not
knowingly collect Personal Information from children under 13. If you are
under 13, do not use this Website in any way. If we learn we have collected
or received Personal Information from a child under 13 without verification
of parental consent, we will take reasonable measures to delete that
Personal Information. If you believe we might have any Personal Information
from or about a child under 13, please contact us at notices@365connect.com

CALIFORNIA PRIVACY RIGHTS

Under California's "Shine the Light" law, California residents who provide
Personal Information (as defined in the statute) in obtaining products or
services for personal, family or household use, are entitled to request and
obtain from us once a calendar year, information about the Personal
Information we shared, if any, with other businesses for marketing uses. If
applicable, this information would include the categories of Personal
Information and the names and addresses of those businesses with which we
shared such Personal Information for the immediately prior calendar year.
To obtain this information please contact us at notices@365connect.com;
please include your full name and physical address.

CAN SPAM ACT

The CAN-SPAM Act is a law that sets the rules for commercial email,
establishes requirements for commercial messages, gives recipients the
right to have emails stopped from being sent to them, and spells out
penalties for violations.

We collect your email address in order to:

Send information, respond to inquiries, and/or other requests or
questions.

Market to our mailing list or continue to send emails to our clients
after the original transaction has occurred.

To be in compliance with CAN-SPAM we agree to the following:

NOT use false, or misleading subject line, “To,” “From,” “Reply-To,” or
routing information.

Identify the message as an advertisement in some reasonable way.

Monitor third party email marketing services used on our behalf for
compliance, if one is used.

Honor opt-out/unsubscribe requests quickly.

Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails,
you can follow the instructions at the bottom of each email and we will
promptly remove you from all correspondence.

ACCESSING AND CORRECTING INFORMATION ABOUT YOU

You can review and change information about you by logging into this
Website and visiting your account profile page. The account profile page is
only provided to Users that use the lease application and rental payments
features. You may also send us an email at notices@365connect.com to
request us to provide, correct or delete any Personal Information about you
that you have provided to us. We may not accommodate a request to change
Personal Information if we believe the change would violate any law or
legal requirement or cause the Personal Information to be incorrect. If you
delete any or all of your postings from the Website, copies of the postings
may remain viewable in cached and archived pages, or might have been copied
or stored by other Website users.

Where we have provided Personal Information about you to a screening
service provider in order to obtain a screening report for the Property
Management Company or Third-Party Provider, the report may contain credit
information. Under Provincial Legislation or the Fair Credit Reporting Act
(15 U.S.C. 1681 et seq.), you may have the right to access, view, and
correct credit information relating to you held by a credit bureau or
credit reporting agency by contacting the credit bureau or credit reporting
agency.

If we collected Personal Information about you on behalf of a third party,
we may have conveyed that information directly to the third party. If so,
it may not exist as part of our own records and you will have to go to the
third party to see the information.

CHANGES TO PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we
decide to change our Privacy Policy, we will prominently post those changes
here and any other place we deem appropriate, so you are always aware of
what Personal Information we collect, how we use it, and under what
circumstances, if any, we disclose it. You should check this Website
frequently to see recent changes.

ACCEPTANCE OF THESE TERMS

By using this Website, or providing any information to us, you acknowledge
that you are aware of the terms of this Privacy Policy. If you do not agree
to the terms of this Privacy Policy or any amended terms, you must not
access or use this Website.

CONTACTING THIS WEB SITE

If you need further assistance, have any questions or concerns about this
Privacy Policy or the handling of your Personal Information, please contact
us by email: notices@365connect.com

LAST UPDATED FEBRUARY 15, 2019

EUROPEAN UNION PRIVACY POLICY

SITE OPERATION

This website and its related downloadable applications and services (collectively, our “Website”) is operated, hosted, and
maintained by 365 Connect, LLC (“365 Connect,” “we,” “our,” or “us”) and is
licensed for use by us to the legal entity (“Subscriber”) that owns or
manages the property featured on this Website (collectively the “Property
Management Company”). In addition to information, materials, products, and
services from the Property Management Company, this Website may also
feature information, materials, products, and services provided by third
parties, including but not limited to, content providers, payment
processors, advertisers, and other service providers (collectively, the
“Third Party Providers”). This privacy policy (“Privacy Policy”) applies
solely to this Website. The terms "you," "your," and "user" (collectively
the “Users”) refer separately to each person (each individual and each
entity for whom the individual acts) that accesses or uses this Website.

Through this Website we assist the Property Management Company in managing
their property and other assets by, among other things, facilitating
communication and transactions between Users, Third Party Providers, and
the Property Management Company. We merely host or process data and
personal information about Users (“Personal Information”) on behalf of the
Property Management Company and Third Party Providers, and have no direct
relationship with Users. We are a data processor and not a data controller
with respect to your personal information.

Our top priority is protecting the privacy and security of any Personal
Information about you collected or used on our Website, as well as
maintaining the trust of our Subscriber. This includes both data submitted
by the Subscriber and Personal Information submitted by Users to our
Website.

This Privacy Policy pertains to Website Users (“you” or “your”) who are
residents of the European Union (“EU”) and access or use this Website. If
you are a resident of the United States or Canada, view our US and Canada Privacy Policy.

We collect and pass on information in connection with the operation and
purposes of our Website, and also collect and pass on information to the
Property Management Company and Third Party Providers to use and share for
its own purposes. This Privacy Policy addresses our collection, use, and
sharing of information about you, and not the collection, use, or sharing
of information about you by the Property Management Company or other Third
Party Providers, as to which you should consult their respective privacy
policies.

We recognize the importance of protecting the privacy of
individual-specific Personal Information collected from our Website Users.
This Privacy Policy describes what Personal Information we gather, how we
use it and how you can correct, change and limit our use of it. It is our
intention to give you as much control over your Personal Information as
possible to preserve your privacy, while still allowing us to utilize that
Personal Information to provide you a valuable service.

We encourage you to read this Privacy Policy and our Website Terms of Use before you send or share Personal Information with us
or use this Website, and to read them again at each return visit.

A USER WHO NAVIGATES THIS WEBSITE GIVES PERMISSION TO US TO SHARE ANY
OR ALL PERSONAL INFORMATION THAT YOU PROVIDE TO THE PROPERTY MANAGEMENT
COMPANY AND THIRD PARTY PROVIDERS WHILE USING THIS WEBSITE IN
FURTHERANCE OF SEEKING TO RENT OR LEASE RESIDENTIAL HOUSING, OR ACCESS
AND USE SERVICES THAT ARE AVAILABLE ON THIS WEBSITE.
IF YOUR DO NOT CONSENT OR AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THIS WEBSITE.
CONTINUED USE OF THIS WEBSITE
CONSTITUTES YOU HAVE FREELY GIVEN SPECIFIC AND INFORMED CONSENT AND
AGREEMENT TO YOUR PERSONAL INFORMATION BEING PROCESSED PURSUANT TO THIS
PRIVACY POLICY.

WEBSITES COVERED UNDER THIS PRIVACY POLICY

This Privacy Policy describes our privacy practices regarding what specific
information we collect from you when you visit this Website, and also any
associated or related Websites (collectively the “Websites”) that contain a
link to this Privacy Statement only.

THIS PRIVACY POLICY DOES NOT APPLY TO OTHER WEBSITES

Our confidentiality, privacy, and other obligations related to the services
we provide to the Property Management Company for the property that is
featured on this Website, is limited to this Website only, and does not
extend beyond this Website. The Property Management Company may own,
operate, license or list the same property on other websites, online
marketplaces, and advertisements, which may contain their own Privacy
Policy and Terms of Use, which we strongly encourage you read before using
those respective websites. The Property Management Company may also use
separately owned or third-party websites for the processing of rental
applications, agreements, payments, and other services to assist you in
either qualifying for rental housing or providing services to you. Those
owned or third-party websites may contact a link on this Website for the
purpose of convenience. Upon clicking a link, you may leave this Website to
engage with those websites, for which they will contain their own Privacy
Policy and Terms of Use, which we strongly encourage you to read before
using those respective websites. Please be advised that this Privacy
Statement is not applicable to those websites, which are instead governed
by their own respective privacy statements.

PLEASE BE ADVISED THAT THIS PRIVACY POLICY IS NOT APPLICABLE TO ANY OF
YOUR PERSONAL INFORMATION THAT IS SHARED BY US WITH THE PROPERTY
MANAGEMENT COMPANY, THEIR PARTNERS, THIRD PARTY PROVIDERS, AND ANY
OTHER THIRD PARTIES TO ASSIST USERS WHO PARTICIPATE IN THE APARTMENT
RENTAL SEARCH, APPLICATION PROCESS, OR WHO MIGHT BECOME RESIDENTS OF
THE PROPERTY FEATURED ON THIS WEBSITE. ALL PERSONAL INFORMATION THAT IS
SHARED BY US WITH THE PROPERTY MANAGEMENT COMPANY, THEIR PARTNERS AND
THIRD PARTIES IS GOVERNED BY THE PRIVACY STATEMENTS OF THE PROPERTY
MANAGEMENT COMPANY, AND THEIR PARTNERS, OR THIRD PARTIES WHO CREATE AND
MANAGE THEIR OWN WEBSITES AND PROVIDE SERVICES TO YOU, AND HAVE NOTHING
TO DO WITH US, AND ARE NOT UNDER OUR CONTROL.

The Property Management Company and Third Party Providers make their own
decisions about how or why Personal Information is to be processed,
including any disclosure or transmission to third parties. If Personal
Information relating to you as an individual has been submitted or entered
into this Website, or was otherwise collected by us on behalf of the
Property Management Company or Third Party Providers, and you wish to
exercise any rights you may have to access, correct, amend or delete such
Personal Information, please contact the Property Management Company or
Third Party Providers directly. If an authorized Property Management
Company or Third Party Providers representative requests that we update or
remove the Personal Information in question, and the Property Management
Company or Third Party Providers has no ability to do so, we will
acknowledge their request within 30 days.

Any use of Personal Information by us is done so pursuant to the agreements
between us, the Property Management Company and any Third Party Providers,
and in accordance with the Terms of Service published on this
Website. This Privacy Policy does not apply to any Personal Information the
Property Management Company or any Third Party Providers may collect or
process from you. If you have any questions or concerns about the data
practices of the Property Management Company or any Third Party Providers
that are using our services to process your Personal Information, you need
to contact them directly, and ask for their Privacy Policy or Privacy
Statement.

PERSONAL INFORMATION WE COLLECT

We collect Personal Information from this Website in order to provide
information, facilitate communication, transactions, and services between
you and the Property Management Company, Third Party Providers, and to help
us better understand how we can assists Users that are searching for
residential apartments to rent, lease, or obtain services as a resident in
the apartment they occupy.

The different types of Personal Information we collect will depend upon
what we will need in order to provide you with the particular product or
service you are interested in. The information requested on our
registration form includes some or all of the following Personal
Information: name, address, email address, telephone number, user name,
password, and birth month, day and year, and will include other information
that you provide voluntarily (i) in connection with your use of any
interactive tools or resources on this Website relating to finding,
leasing, or accessing services for an apartment, including submission of an
inquiry, contact or schedule a visit form, lease application or related
payment, such as your name, social security number, social insurance
number, driver's license number, present and prior postal addresses, zip
codes, postal codes, telephone numbers and email addresses, monthly rent
paid at previous residences, gender, age, marital status, date of birth,
employers, job titles, occupation, income, references, and payment-related
information, such as credit card information, bank account information and
routing numbers, emergency contact information, and information about your
pets and vehicles, including license plate numbers, (ii) in connection with
your submission of rental payments, service requests, or other
communications with the Property Management Company, its agents or Third
Party Providers, such as your name, address, telephone number, email
address, automated clearing house (ACH) information, debit or credit card
information, and/or the nature of work requested, (iii) in connection with
your use of any interactive educational or informational resources provided
to residents, (iv) in any postings you make in any Community or otherwise
on our Website or in any emails that you send to us, (v) in connection with
your use or purchase of any other services or products provided by this
Website or by any Third Party Providers, such as your debit or credit card
information and your purchase history, or (vi) in connection with your use
of any other aspect of this Website. Certain services and features on this
Website may only be used if you voluntarily provide certain information
about you.

Those interested in touring, inquiring, renting or leasing a residential
apartment will likely be asked to include the following additional
information: the type of apartment or apartment size you are looking for,
where you want to live, the type of building you prefer, your proposed rent
budget, the number of individuals in your household and their ages, and if
you have pets or not.

THIS INFORMATION WILL BE SHARED WITH THE PROPERTY MANAGEMENT COMPANY OR
THIRD PARTY PROVIDERS THAT OWN, MANAGE, SERVE, OR OPERATE THE
RESIDENTIAL APARTMENTS YOU ARE SEEKING TO RENT, LEASE, OR OBTAIN
SERVICES AS A RESIDENT IN THE APARTMENT YOU OCCUPY.

USAGE TRACKING: USE OF IP ADDRESSES

Every device that connects to the Internet is given a number that is known
as an Internet Protocol (IP) Address. These numbers are typically assigned
in geographic blocks. An IP address can often be used to identify the
location from which a device is connecting to the Internet. As permitted
under applicable law, we collect IP addresses for the purposes of system
administration, gathering and analyzing aggregated information, creating a
better experience for Users and auditing the use of our site.

We do not usually link any IP addresses to anything that can be personally
identifiable. This means that your Internet session will be logged, but you
will remain anonymous to us. We will seek to link your IP address to
personally identifiable information when we deem it necessary (i) to
identify and authenticate you when you submit certain information to the
Website, such as request to visit the property, payments, request for
services or other types of communication, (ii) to be pre-qualified for
rental housing displayed on this Website, (iii) when you start or complete
a lease application for rental housing displayed on this Website, or (iv)
to protect this Website and other Users from harm and to prevent criminal
misconduct.

USE OF COOKIES

A cookie is a small file which contains a string of characters that is sent
to your computer when you are browsing the Internet and visit a website.
When you visit the same website again, the cookie enables that site to
recognize your browser. Cookies may store User preferences and other
information about you. You can configure your browser to refuse all
cookies, or to indicate when a cookie is being sent. However, there are
some website features or services that may not function properly without
cookies.

Improvements and updates to this Website are based on such data as total
number of visitors and pages viewed. This information is most easily
tracked with cookies. We use the information from cookies only to provide
services better suited to your needs, and for the protection of our Website
and Users from potential harm. We never save passwords or credit card
information in cookies.

We may use cookies for many purposes, including to remember your safe
search preferences, to track Users’ movements around this Website, to
analyze trends, administer this Website, to count how many visitors we
receive to a page, to help you sign up for our services, to protect your
data and to gather demographic information about our User base as a whole.
Users can control the use of cookies at the individual browser level. We
may partner with a third party to either display advertising on our website
or to manage advertising on other sites. A third party partner may use
cookies or similar technologies in order to provide advertising or other
content to you, based upon your browsing activities and interests or to
make the ads you see more relevant to you.

If you desire to change your cookie preferences, you can do so through your
browser settings. You may also limit the information we learn from certain
cookies by logging directly into the registered areas of this Website
rather than by logging in by using your social media log-in credentials. Be
advised that our cookies are often used to provide you with certain
functionality, and without them you may not be able to use some of the
services provided on this Website.

WEBSITE ANALYTICS

This Website may use web analytics tools and services, some from third
parties, such as web analytic services provided by Google, Inc. (“Google”),
to better assist us in understanding how this Website is used. These web
analytics tools and services will place cookies on your computer that will
generate information that we select about your use of this Website,
including your computer’s Internet Protocol (IP) Address. That information
will be transmitted to and stored by us and or third parties. The
information will be used for the purpose of evaluating consumer use of this
Website, compiling reports on Website activity for our use, and providing
other services relating to Website activity and usage. We may also transfer
this information to third parties where required to do so by law, or where
such third parties process the information on our behalf. You may refuse
the use of cookies by selecting the appropriate settings on your browser.
Please note that by doing so, you may not be able to use the full
functionality of this Website. Use of cookies by Google Analytics is
covered by Google’s privacy policy located at
https://policies.google.com/privacy.

OUR USE OF INFORMATION ABOUT YOU

We may use Personal Information about you to create your account, to enable
you to use this Website, including any communities, and to facilitate
communication and transactions between Users and the Property Management
Company, and other Third Party Providers for transactions between you and
any of them through this Website, including but not limited to using
information about you (i) in connection with any interactive
decision-making tools or resources relating to leasing an apartment,
including submission of an inquiry, contact or schedule a visit forms,
lease application or related payments, (ii) in connection with assisting
the Property Management Company and Third Party Providers in marketing to
you, including contacting you by email, phone, text message, or otherwise,
(iii) in connection with assisting the Property Management Company and
Third Party Providers in processing your lease application, including
investigating your background, leasing history, and creditworthiness
through third parties, including consumer reporting agencies, (iv) in
connection with processing your rental payments, service requests, and
other communications with the Property Management Company and Third Party
Providers, (v) in connection with your use of any interactive educational
or informational resources provided to residents, (vi) in connection with
your participation in any community or in dealing with any emails that you
send to us, (vii) in connection with your use or purchase of any other
services or products provided by this Website or by any third-party
provider, (viii) in connection with your use of any other aspect of this
Website, and (ix) generally to enhance and optimize your use of this
Website. We may also use your email address or telephone number to respond
when you submit a question, suggestion, or request assistance with using or
accessing this Website.

We may link Personal Information we collect about you with other Personal
Information we collect about you, whether offline or from third parties or
otherwise. We may use Personal Information about you to send you targeted
messages, publications, news, and information about events, special offers,
promotions, benefits, and other advertisements. We may use Personal
Information about you to improve, to analyze trends, to administer this
Website, to gather demographic information about this Website's users, to
track user movements, and to customize the content and layout of this
Website for each individual user.

INFORMATION WE SHARE OR DISCLOSE

We may share Personal Information about you with the Property Management
Company, Third-Party Providers and others (such as hosting service
providers, analytics service providers, email service providers, lease
screening service providers, custom programmers, payment processors,
advertisers, etc.) and other appropriate persons for purposes of (i)
performing functions pertinent to this Website's apparent and reasonable
purposes, including but not limited to those discussed above under "Our Use
of Information About You"; (ii) maintaining, upgrading, and improving this
Website; (iii) complying with law, cooperating with governmental
authorities, and consulting with our attorneys and other advisers; (iv)
attempting to avert a threat of harm to our, or others' safety, or other
interests; (v) defending us and our members, managers, officers, employees,
and affiliates in connection with any legal actions or claims; and (vi)
enforcing the Terms of Use of this Website. We also reserve the
right to transfer personal information about you to a third party that
acquires substantially all of our assets.

Similarly, the Property Management Company, Third-Party Providers and
others (such as lease screening service providers, payment processors,
advertisers, etc.) may share Personal Information about your use of this
Website with other appropriate persons for purposes of (i) performing
functions that would reasonably be expected of a Property Management
Company with respect to a prospective renter, such as contacting you by
email, phone, text message, or otherwise to market its space and
investigating your background, leasing history, creditworthiness, either
directly or through the assistance of third parties, including credit
reporting agencies, (ii) complying with law, cooperating with governmental
authorities, and consulting with attorneys and other advisers, (iii)
attempting to avert a threat of harm to its, or others' safety, or other
interests, (iv) defending it and its owners, personnel, and affiliates in
connection with any legal actions or claims, and (v) other purposes of the
Property Management Company in or outside the ordinary course of its
business.

We may use Third-Party Providers to send and distribute email and to
perform other marketing and support functions. We may share Personal
Information about you with third parties who offer goods and services we
think may be of interest to you. From time to time, we may cooperate with
other organizations or companies to provide co-sponsored or co-branded
promotions, services or events and may share Personal Information about you
with our co-sponsor. We also may provide Personal Information about you to
service providers or contractors to perform functions on our behalf, such
as, but not limited to, companies or individuals hired to: communicate
news, deliver our promotional materials via e-mail and direct mail, to
develop, enhance, market or provide any of our products, to process credit
card payments and to assist us with sending communications and performing
other marketing and support functions. These third parties may use
technologies to measure the effectiveness of ads and emails, and use
Personal Information about your visits to this Website so that we may
provide you with a better experience on this Website. We also may use
third-party social media platforms, including third-party social media
websites, to communicate with you. We also may share with third parties
aggregated demographic and statistical information, such as the daily
number of unique visitors to this Website, the number of users who searched
for certain types of housing, and how many users clicked on a particular
advertisement.

We also may disclose Personal Information about you (i) to a person who in
our good faith judgment appears to be you or your agent, (ii) to a third
party or parties where disclosure is required or permitted by law, a
judicial proceeding, a criminal investigation, a court order, or legal
process, (iii) if, in our good faith judgment, it is necessary or desirable
to enforce compliance with our internal policies or the Terms of Use
, to try to prevent illegal activity or suspected fraud, or to try to
protect this Website, customers, or others; and (iv) to any other entity
that acquires all or a portion of our organization by merger,
reorganization, operation of law, or a sale of some or all of our assets.

Through this Website, we may make available areas that allow for User
interaction with other users, such as blogs, forums, bulletin board
services, chat areas, or other message and communications features. Some of
these forums may require registration. Please remember that any Personal
Information that is disclosed in these areas becomes public information,
and you should exercise caution when deciding to disclose Personal
Information about yourself.

We do not rent or sell your Personal Information in a personally
identifiable form to anyone, provided however, certain Personal Information
may be shared with the Property Management Company, Third-Party Providers
and others such as hosting service providers, analytic service providers,
email service providers, lease screening service providers, custom
programmers, payment processors, advertisers as more fully described above.

We may anonymize your Personal Information so that you are not individually
identified, and provide that information to our partners and also third
parties. We may also provide aggregate usage information to our partners,
who may use such information to understand how often and in what ways
people use our Website, so that they, too, can provide you with an optimal
online experience.

Advertisers: We may allow advertisers and/or merchant partners
(“Advertisers”) to choose the demographic information of Users who will see
their advertisements or promotional offers, and you agree that we may
provide any of the Personal Information we have collected from you in a
form that is not personally identifiable to Advertisers, in order for that
Advertiser to select the appropriate audience for those advertisements
and/or offers. For example, we might use the fact you are located in
Houston to show you ads or offers for Houston businesses, but we will not
tell such businesses who you are. Or, we might allow Advertisers to display
their ads to Users with similar usage patterns to yours, but we will not
disclose usage information to Advertisers except in aggregate form, and not
in a manner that would identify you personally. Note that if an advertiser
asks us to show an ad to a certain audience or audience segment, and you
respond to that ad, the advertiser may conclude that you fit the
description of the audience they were trying to reach.

Affiliated Businesses: In certain situations, businesses or third party
websites we might be affiliated with may sell or provide products or
services to you through, or in connection with this Website (either alone
or jointly with us). You can recognize when an affiliated business is
associated with such a transaction or service, and we will share your
Personal Information with that affiliated business only to the extent that
it is related to such transaction or service. We have no control over the
policies and practices of third party websites or businesses as to privacy
or anything else, so if you choose to take part in any transaction or
service relating to an affiliated website or business, please review all
such businesses’ or websites’ policies.

Agents: We might employ other companies and people to perform tasks on our
behalf and need to share your Personal Information with them to provide
products or services to you. Unless we tell you differently, our agents do
not have any right to use the Personal Information we share with them
beyond what is necessary to assist us.

REVIEWS AND CONTENT SUBMISSIONS

This Website may allow you to provide and submit certain content
(“Content”) in the form of a review or rating as to your experience in
visiting or living at the properties featured on this Website. We may share
your content with the Property Management Company, Third-Party Providers
and others (such as review publishers, search engines, analytic service
providers, syndication sites, advertisers, etc.), and other appropriate
persons for purposes of publication to this Website, social media channels,
as well as other third party websites.

THIRD PARTY PROVIDERS

It is our intention to maintain reputable Third-Party Providers to offer
Users a variety of products and services on this Website. We are not
responsible for their information, privacy, or other business practices.
When choosing to purchase products or services on this Website, you must
take into consideration that you will be transacting business directly with
a Third-Party Provider, and the Personal Information about you, collected
by the provider, will be subject to the practices of that provider.

THIRD PARTY WEBSITE LINKS

This Website may contain links to third party websites that are beyond our
control, and take you outside of this Website. For example, if you "click"
on a banner ad, which is an advertisement or a search result, the "click"
may take you off this Website and on to another site that is beyond our
control. These other websites may include sites of other sponsors,
advertisers or partners that may use their logo with ours as part of a
co-branding agreement. These other websites might also send their own
cookies to Users who become visitors to their websites to collect data or
solicit information. We do not control these websites and therefore are not
responsible for their content. The inclusion of hyperlinks to any other
websites by us on this Website, does not infer any endorsement of the
content or material on such websites, nor any association with the owners
or operators of the websites or the businesses listed on any of these
websites. Our policies do not extend to anything that is inherent in the
operation of the Internet, which is beyond our control. Be advised that if
you disclose Personal Information online, that all such Personal
Information may be collected and used by people you do not know.

The information practices or content of such other websites or advertisers
is governed by the privacy statements of all such other websites and
businesses contained on those websites. Please be advised that this Privacy
Statement is not applicable to those websites and businesses, which are
instead governed by their respective privacy statements. Please review the
privacy statements of such other websites and businesses to understand
their Personal Information collection practices.

DATA TRANSFERS

Be advised that if you provide Personal Information to this Website, it may
be transferred to, and processed on computers in the United States of
America or other countries, which are not in the EU. Please do not provide
your Personal Information to us if you do not want this information to be
transferred outside of your country, or if the laws in your country
restrict these types of transfers.

TRACKING

When this Website receives web browser "do not track" signals (or other
mechanisms that provide consumers the ability to exercise their choices
regarding the collection of personally identifiable information about a
consumer's online activities over time and across third-party websites or
online services), our Website does not alter its behavior. Other parties
may collect personally identifiable information about an individual
consumer's online activities over time and across different websites when
the consumer uses this website or its services.

SAFEGUARDING YOUR INFORMATION

We take all reasonable and appropriate measures to protect your Personal
Information from loss, misuse and unauthorized access, disclosure,
alteration and destruction; taking into account the risks involved in the
processing and the nature of the Personal Information.

Our resident services and application accounts require a username and
password to log in. You must keep your username and password secure, never
disclose it to a third party, and do not allow others to utilize your
account. You should fully exit from your account at the end each session,
by utilizing the logout feature. You should also implement a practice of
changing your password on a regular basis. If Users have any questions
about security, please contact us at: notices@365connect.com

EMAIL CONSENT AND OPT-OUT

By providing Personal Information to us on our Website, you give
affirmative consent that we may reach out to you by email, and provide you
with information and notices relating to you searching for residential
apartments to rent, lease, or obtain services as a resident in the
apartment you occupy, and with regard to other properties or services that
may be available and of interest to you in the future.

You may choose to opt out of receiving future commercial email messages
from us as a result of your registrations with us. Each email sent by us
will have a link with instructions on how to remove yourself from our email
list.

CHILDREN'S PRIVACY

Our Website is not intended for children under 13 years of age. We do not
knowingly collect Personal Information from children under 13. If you are
under 13, do not use this Website in any way. If we learn we have collected
or received Personal Information from a child under 13 without verification
of parental consent, we will take reasonable measures to delete that
Personal Information. If you believe we might have any Personal Information
from or about a child under 13, please contact us at notices@365connect.com

FIXING AND DEACTIVATING PERSONAL INFORMATION

You have the right whenever you choose, to request that we let you know
whether or not Personal Information relating to you is being processed. You
have the right to request that we fix, correct, supplement, delete or block
your Personal Information in the event that the data is inaccurate,
incomplete or irrelevant to the purposes of the processing activities, or
if the Personal Information is being processed in any other way, which
infringes a legal provision. If you desire to exercise your rights, or if
you have any questions, concerns or suggestions regarding the use,
collection, or security of your Personal Information, please contact us at notices@365connect.com.

When a User requests that certain information about them be deleted, we
will make all reasonable efforts to remove that data from our systems. Be
advised that due to the nature of the Services that we provide, some
information about you may not be fully deleted due to backups or archived
copies; however, such information will only be used for the purpose of what
our Website does, which is to provide information, facilitate
communication, transactions, and services between you and the Property
Management Company or Third-Party Providers in relation to you searching
for residential apartments to rent, lease, or obtain services as a resident
in the apartment you occupy.

CHANGES TO PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we
decide to change our Privacy Policy, we will prominently post those changes
here and any other place we deem appropriate, so you are always aware of
what Personal Information we collect, how we use it, and under what
circumstances, if any, we disclose it. You should check this Website
frequently to see recent changes.

CONTACT INFORMATION

If your Personal Information changes, which includes zip or postal code,
phone, email or postal address, we offer a way to correct, update, delete
or deactivate Users' Personal Information, through either logging into your
account, if you registered for one, or by contacting us at notices@365connect.com

You may use this email to contact us for any other reason relating to this
Privacy Policy. Your e-mail should state that it is a “data protection
question” and that it is “time sensitive.”

GDPR INFORMATION

The EU General Data Protection Regulation ("GDPR") was placed in effect on
May 25, 2018. This section of the Privacy Policy constitutes a Notice to
you as a data subject for purposes of the GDPR, and sets forth our
processing of your personal data (as defined in the GDPR).

CORPORATE INFORMATION

This website and its related downloadable applications and Services is operated, hosted, and maintained by 365 Connect, LLC.
Please see the "Contact Information" section for information on
how to contact us.

TYPES OF PERSONAL INFORMATION PROCESSED BY US

We collect Personal Information from this Website in order to provide
information, facilitate communication, transactions, and services between
you and the Property Management Company or Third-Party Providers, and to
help us better understand how we can assists Users that are searching for
residential apartments to rent, lease, or obtain services as a resident in
the apartment they occupy. Please see the “Personal Information We Collect"
and “Usage Tracking: Use of IP Addresses" sections for more information.

THE PURPOSE AND LEGAL BASIS FOR PROCESSING

We process Personal Information for our legitimate interest of operating
this Website to make Users aware of the Property Management Company’s
products and services. Please see the “Personal Information We Collect"
section for more information.

RECIPIENTS

We may transfer Personal Information to our other entities, primarily
entities in the United States of America and others in or outside the EU,
and to our service providers and affiliates who host and/or provide our IT
system. We may also transfer Personal Information with third-party
professional advisors who provide accounting, consultancy, and legal
services to us. Please see the "Information We Share or Disclose" section
for more information.

INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed on computers in the
United States of America and other countries, which are not in the EU.
Please see "Data Transfers” section for more information.

DATA SUBJECTS RIGHTS

Please see the "Email Consent and Opt-Out," and "Fixing and Deactivating
Personal Information" section for more information. In addition to
these rights, you may have data portability rights. Please see the "Contact
Information" section to contact us about any of your rights.

REGULATORY BODY

You may contact the national data processing authority in the EU
jurisdiction in which you would normally access this Website if you have
any concerns regarding the processing of your Personal Information.

ACCEPTANCE OF THESE TERMS

By using this Website, or providing any information to us, you acknowledge
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